DRC-2025-000370

CLIVE SITE
LETTER OF TRANSMITTAL DATE: 1/28/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-006
Description of Documents Transmitted Qty
See attached for update to Container Handling. CL-CH-PR-205 Rev 8, Decontamination Procedure 1
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Please replace your current procedure revisions with the documents within this Transmittal. You are not required to sign any documents to verify receipt of this distribution. However, you should make every effort to ensure that your copy of the License is current. FROM: EnergySolutions
Document Control Clive Facility
Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
CL-CH-PR-250

Decontamination Procedure
Revision 8

Authored By:
Roger Ekins, Waste Disposal Supervisor

Date
Reviewed By:
Reviewed By:
Kelly Medrano, Container Decon and Storage
Supervisor

Date
Curtis Kirk, Quality Assurance Manager Date
Approved By
Thomas A. Brown, Radiation Safety Officer
(RSO) Date
Approved By
Brennon Dick, Operations Manager Date

Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation

Roger Ekins Digitally signed by Roger Ekins
Date: 2025.01.27 11:58:38 -07'00'
Kelly Medrano Digitally signed by Kelly Medrano
Date: 2025.01.27 13:55:22 -07'00'
Digitally signed by Curtis Kirk
DN: C=US, OU=EnergySolutions, O=Quality Assurance, CN=Curtis Kirk, E=[e-mail]
Reason: I am the author of this document
Location: your signing location hereDate: 2025-01-27 14:34:25
Foxit PhantomPDF Version: 9.7.5
Curtis Kirk
Digitally signed by Thomas BrownDN: OU=Health Physics, O="EnergySolutions, LLC", CN=Thomas Brown,
E=[e-mail]
Reason: I am approving this document
Location: Clive
Date: 2025-01-28 05:55:16Foxit PhantomPDF Version: 9.7.5
Thomas Brown
Brennon Dick Digitally signed by Brennon Dick
Date: 2025.01.28 15:22:05 -07'00'
Adobe Acrobat version: 2024.005.20320
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Table of Contents

1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose........................................................................................................................... 3
1.2 Scope............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3 GENERAL .............................................................................................................................. 3
3.1 Definitions ...................................................................................................................... 3
3.2 Responsibilities .............................................................................................................. 4
3.3 Precautions and Limitations ........................................................................................ 5
3.4 Records........................................................................................................................... 5
4 REQUIREMENTS AND GUIDANCE .................................................................................. 5
5 ATTACHMENTS AND FORMS........................................................................................... 7

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1 PURPOSE AND SCOPE
1.1 Purpose
The purpose of this procedure is to provide guidelines for operation of the
decontamination facilities which include the Intermodal Container Wash Facility
(ICWF), Track 4 Rail Wash Facility and Mixed Waste Wash Pad/Bay.
1.2 Scope
This procedure applies to all EnergySolutions personnel who will be involved in
operation of the listed facilities.

2 REFERENCES
2.1 ES-SH-PR-110, Hazardous Energy Control (Lockout/Tagout)
2.2 ES-SH-PR-105, Fall Protection
2.3 29 CFR 1926.1053, “Ladders”
2.4 ES-QA-PR-005, Records
2.5 ES-SH-PR-106, Personal Protective Equipment
2.6 CL-SH-PR-100, Clive Health and Safety Program
2.7 CL-LD-PR-020, Management and Disposal of LLRW, and 11e.(2) and Mixed
Waste
2.8 Appendix J, Ground Water Quality Discharge Permit BAT Performance
Monitoring Plan.
2.9 Appendix K, Ground Water Quality Discharge Permit BAT Contingency Plan.
2.10 CL-CH-PR-252, Incoming Shipment Inspecting and Sampling
2.11 CL-RS-PR-115, Radiological surveys
2.12 CL-SR-PR-062 Rail Safety and Operations
3 GENERAL
3.1 Definitions
3.1.1 BAT – Best Available Technology: The application of design, equipment,
work practice, operation standard, or combination thereof, at a facility to
effect the maximum reduction of a pollutant achievable by available
processes and methods taking into account energy, public health,
environmental and economic impacts and other costs.
3.1.2 ICWF- Acronym used throughout this procedure in place of Intermodal
Container Wash Facility.
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3.1.3 Pressure Wash System – A high-pressure water spray system consisting of
pump, high-pressure hose, spray nozzle and associated piping. It is
engineered to provide a continuous jet spray for decontamination of
containers, railcars and other equipment.
3.1.4 Identification (ID) Label – Labels affixed to each container that are used
to identify the waste material and that an inspection has been completed.
Other information may also be included on the label to assist field
personnel in handling of the container.
3.1.5 Sump Sludge – A precipitated semi-solid matter produced during the
decontamination of containers. This sump sludge shall be managed as
onsite-generated waste.
3.1.6 Tripod – Mobile steel structure used as bracing underneath an intermodal
door to secure the door open during work activities inside the container.
3.1.7 Mixed Waste Contaminated Areas – The areas at Mixed Waste that
contain possible surface contamination. These areas include the MW
Landfill Cell, Wash Pad, Wash Bay, and the Treatment Building.
3.1.8 Polychlorinated Biphenyl’s (PCB’s): As defined in 40 CFR 761.61
through 64.
3.1.9 PCB Wipe: A cloth wipe soaked in Hexane used to determine removable
PCB contamination on a container.
3.1.10 Triple Rinse - Consists of rinsing three times using water or a solvent
capable of removing contaminants.
3.2 Responsibilities
3.2.1 The Operations Manager has overall responsibility for the implementation
of this procedure.
3.2.2 The Container Decon and Storage Supervisor is responsible for
coordinating decontamination activities with the Foreman or designee,
supplying personnel equipment necessary to perform their duties in a safe
and compliant manner.
3.2.3 The Container Handling Foreman or designee is responsible for:
• Maintenance and upkeep of wash guns, and all other equipment
used in the decontamination facilities.
• Facilitating the return of containers for rail and truck shipments.
• Ensuring decontamination personnel perform all job function
activities safely and compliantly.
• Compliance with procedures
3.2.4 Decontamination personnel are responsible for the actual washing of the
boxes and the clean-up of the decontamination facilities.
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3.2.5 Radiation Safety Technicians (RST) shall ensure the radiological release
criteria are met after decontamination operations and the RWP
requirements are followed.
3.3 Precautions and Limitations
3.3.1 Personnel involved in the washing and decontamination of
containers/equipment in the listed facilities shall be qualified or under
direct supervision of a qualified operator, and have received training on
the proper safe use of all equipment.
3.3.2 The foreman or designee shall ensure daily pre-operational inspection of
the facility in use is performed prior to decontamination operations.
3.3.3 If any discrepancies are found the foreman or designee shall note the
discrepancy on the pre-operational checklist, and contact the Maintenance
department when necessary for repairs.
3.3.4 Operation of the wash facilities shall be stopped in the event of a failure or
elimination of any safety device (e.g. guards, shields, covers, control
switches, etc.)
3.3.5 When washing railcars, decontamination personnel shall enter or exit
using caution, and maintaining three point contact.
3.4 Records
3.4.1 Decon Facility Pre-operational Checklist, CL-CH-PR-250 F1, shall be
completed daily for the ICWF, Track 4 Rail Wash Facility, and Mixed
Waste Wash Pad/Bay and reviewed by the supervisor or designee. The
completed document will be transmitted to document control within 45
days.
3.4.2 Triple Rinse Verification, CL-CH-PR-250 F2, shall be completed monthly
for the Mixed Waste Wash Pad/Bay and reviewed by the supervisor or
designee. The completed document will be transmitted to document
control within 45 days.
3.4.3 Damaged Container Report, CL-CH-PR-250 F5, shall be completed as
necessary to document any damage to the conveyance/container. The
completed document will be reviewed by the supervisor or designee. The
completed document will be transmitted to document control within 45
days.
3.4.4 Inspection/Wash Log, CL-CH-PR-250 F6, shall be completed as necessary
to document container decon and inspection activities. The completed
document will be reviewed by the supervisor or designee. The completed
document will be transmitted to document control within 45 days.
4 REQUIREMENTS AND GUIDANCE
4.1 Safety
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4.1.1 Personnel shall wear the appropriate Personal Protective Equipment (PPE)
as defined in the RWP, and in accordance with Reference 2.5, Personal
Protective Equipment and applicable JHA(s)
4.1.2 Work performed on or around rail such as in the rail wash facility shall be
in accordance with Reference 2.12, CL-SR-PR-062 Rail Safety and
Operations.
4.1.3 Personnel shall “stop work” if any unsafe condition or practice is
observed.
4.1.4 Prior to washing containers mounted on a transport trailer, the decon
operator shall ensure the trailer is secure to prevent movement.
4.1.5 When washing Intermodal containers that have a tailgate or door that lifts
up the following shall be followed:
• Personell shall carefully lift tailgate/door with mechanical aid
while all other employees stand clear.
• Tripod and or adequate support shall be positioned under
tailgate/door. Personnel positioning tripod/support shall at no time
be in the swing area of the tailgate/door
4.2 Compliance
4.2.1 Prior to changing waste types (e.g. 11e.(2) to Class A or Class A to
11e.(2), all vehicles and equipment used shall be inspected and labeled in
accordance with Reference 2.7, Management and Disposal of LLRW,
11e.(2) and Mixed Waste.
4.2.2 When removing sludge from the sump or cleaning the bays after
decontaminating 11e. (2) waste containers/equipment, the sludge and other
removed material shall be placed in a container that is appropriately
labeled for the waste type.
4.2.3 A container which previously held hazardous waste shall be RCRA empty
prior to reuse with a different waste stream, and triple rinsed as necessary
before use other than inside the Mixed Waste Facility.
4.3 Procedure
4.3.1 Prior to beginning work the decon foreman or designee shall perform an
initial visual inspection of the facility to ensure it complies with the
requirements outlined in Reference 2.8, Appendix J, Ground Water
Quality Discharge Permit BAT Performance Monitoring Plan.
4.3.2 During the inspection or at any time during operations if a BAT failure is
detected the decon foreman or designee shall follow the actions outlined
in: Reference 2.9, Appendix K, Ground Water Quality Discharge Permit
BAT Contingency Plan.
4.3.3 A formal BAT inspection will be performed each day in accordance with
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Reference 2.8, Appendix J, Ground Water Quality Discharge Permit BAT
Performance Monitoring Plan.
4.3.4 Equipment or containers that have come in direct contact with open mixed
waste or non-lined containers that contained mixed waste shall be triple
rinsed before leaving the mixed waste area.
4.4 Decontamination Process
4.4.1 The decon foreman or designee shall verify the status of each conveyance.
4.4.2 Decontamination personnel may use a pressure wash system for
decontamination of railcars and other equipment.
Note: Although utilizing the pressure washer is the preferred
method for decontaminating, alternate methods to
include but not limited to hand wiping, grinding,
scrubbing, gritblasting, and sandblasting can be
utilized. Appropriate JHA’s and RWP’s shall be
followed when performing this work.
4.4.3 Determined PCB contaminated waste containers are: containers in which
the liner has been breached and residual contamination on the surface
exceeds 10 ug/100 cm2. When PCB decontamination is required, it shall
be completed before radiological decontamination.
4.4.4 Select a solvent that demonstrates the ability to remove PCB’s. Examples
of solvents that may be used are Diesel Fuel, N-Hexane, etc.
4.4.5 All solvents, absorbent pads, etc. used to decontaminate PCB’s shall be
collected and solidified. Disposal methods for PCB decon waste is to be
approved by the Environmental Engineer.
4.4.6 Collect a PCB wipe in accordance with CL-CH-PR-252, Incoming
Shipment Inspecting and Sampling procedure and submit to the lab for
analysis. If results are passing, remove PCB labels.
4.4.7 The RST shall ensure the radiological release criteria are met after
decontamination operations.

5 ATTACHMENTS AND FORMS
5.1 CL-CH-PR-250-F1, Decon Facility Pre-Operational Checklist
5.2 CL-CH-PR-250-F2, Triple Rinse Verification
5.3 CL-CH-PR-250-F5, Damaged Container Report
5.4 CL-CH-PR-250-F6, Inspection/Wash Log

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Attachment 5.1 – CL-CH-PR-250 F1
Decon Facility Pre-Operational Checklist

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Attachment 5.2 – CL-CH-PR-250 F2
Triple Rinse Verification

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Attachment 5.4 – CL-CH-PR-250 F5
Damaged Container Report

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Attachment 5.5 – CL-CH-PR-250 F6
Inspection/Wash Log

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